Dan Juhl
DanMar & Associates, Inc.
996 190th Ave.,
Woodstock, MN 56186



December 2, 2002



Pandor Hadjy
Assistant Deputy Administrator
Business Programs, RBS, 
Room 5050 South Agriculture Building, Stop 3220 
1400 Independence Avenue, SW., 
Washington, D.C. 20250-3220, 
telephone: 202-720-9693.


RE:  Section 9006 Implementation


To the Rural Business Service:

	DanMar & Associates is a small business located in rural Minnesota, developing 
renewable energy projects to provide bulk power for sale to the electric distribution grid. We 
primarily develop wind projects but have also pioneered the development of hybrid systems 
integrating wind with other generation technologies.  We are pleased to see USDA moving 
forward with the process of implementing Section 9006 of the Farm Bill, and encourage the 
department to continue to do so as quickly as possible via either immediate rules or via a Notice 
of Funding Availability.

	DanMar & Associates specializes in the development of wind projects up to 5 MW in 
scale that feature local ownership and use local construction contractors.  We are a recognized 
leader in this field, widely referenced in both the mass media and specific trade publications, 
including for instance a recent piece on small wind farm project finance in the Farm Bureau 
“Voice of Agriculture” publication (see: http://www.fb.org/views/focus/fo2002/fo1014.html ). 

       From our perspective as a small business in renewable energy in Minnesota, we see 
several key opportunities for Section 9006, and we recommend the following types of projects as 
eligible for grants, loans and/or loan guarantees under the section.  

1.	“Wind Energy Cash Crop” Grants, Loans, and  Loan Guarantees: 
       Farmers, ranchers, and rural small businesses may apply for grants, loans, and loan 
guarantees for wind projects with a nameplate capacity between 70 kW and 10 MW.  The 
primary purpose such a program is to support the development of wind projects where the owner 
seeks to market bulk renewable power through the electric distribution grid and where the wind 
energy production is therefore a “cash crop” similar to other farm commodities.  Grants would  
not need to exceed 15% of the total project cost, and loans and loan guarantees may not exceed 
50% of the total project cost.  
       We recommend support for such large “utility-scale” wind projects because we believe 
this program of grants, loans, and loan guarantees can demonstrate practical business models for 
projects of this scale, as well as significant rural economic development benefits.  Locally-owned 
projects in the range of 1 MW to 10 MW are very likely to use local planning and construction 
contractors and therefore maximize local economic development benefits. Furthermore, with 
existing incentive programs offered by states such as Minnesota, Illinois, New York, and 
California, the market for such projects could be scaled up very quickly.  We do not, however, 
recommend support for projects larger than 10 MW.  Developers of projects larger than 10 MW 
tend to have access to capital and financial expertise that lower their need for financial support 
relative to smaller project developers such as FPS. Furthermore, projects much larger than 10 
MW are likely to conflict with the definition of a rural small business as one with gross annual 
revenues of under $1 million.

2.	Distributed Generation Small-Scale Renewable Energy Projects:
       Farmers, ranchers and rural small businesses may apply for grants, loans and/or loan 
guarantees for wind, solar, and biomass gasification projects for projects up to $100,000 in total 
cost.  Grants shall not exceed $25,000 under this subsection. The primary purpose of this 
subsection is to support the growth of renewable distributed generation projects serving the 
project owners’ own electric load. 
       
       The primary beneficiary of such projects is likely to be independent farmers seeking to 
install small wind turbines in the range of 10 kW.  Such projects represent a significant 
democratization of energy production in America and should be strongly encouraged.  The 
technology today is often not cost-effective in the absence of state or federal supports, but with 
larger production scales certainly could be cost effective, so we recommend support for such 
projects.

	We’d like to thank the USDA for this opportunity to comment on the implementation of 
Section 9006, and look forward to the successful implementation of the Energy Title.

Sincerely,



Dan Juhl